Dta Agreement With Japan
4. Enterprises of a Contracting State the capital of which is whote or in part or under the direct or indirect control of one or more residents of the other Contracting State may not be subject in the first-mentioned Contracting State to any taxation or requirement which is different or heavier than the taxation and requirements to which other similar enterprises of the first-mentioned Contracting State are subject n or may be subject. (5) 5.Notwithstanding Article 2, the provisions of this Article shall apply to corporation tax in Japan and to each of those taxes if and when such tax is levied in India. Most EU Member States have signed a bilateral tax treaty with Japan to avoid double taxation, prevent tax evasion and avoidance and promote investment and economic trade. The Department of Finance regularly reports on the status of tax treaty negotiations. In general, international tax treaties shall contain the following definitions and rules, but are not exhaustive: c. for the purposes of the credit referred to in points (a) and (b), the amount shall be deemed to have been paid by the taxable person who would have been paid under Indian law and in accordance with this Agreement as Indian tax if the Indian tax had not been reduced or reduced in accordance with the special incentives for economic development in India; which are effective on the date of signature of this Agreement or which, in the future, may be introduced into Indian tax legislation amending or supplementing existing measures, provided that an agreement is concluded between the two Governments on the extent of the benefit conferred on the taxable person by the above-mentioned measures. Me. any person having the nationality of India; (ii) all legal persons, partnerships and associations that de-establish their status as such under the laws in force in India; (a.b.c i.e.c. “international traffic” means any carriage by ship or aircraft operated by an enterprise of a State Party, unless the ship or aircraft is operated exclusively between places in the other State Party; j. “competent authority” means, i. in Japan, the Minister of Finance or his plenipotentiary representative; ii. In India, the central government to the Ministry of Finance, the Ministry of Finance or their authorized representative.
1. 2. With respect to the application of this Convention by a State Party, any concept not defined therein, except where the context so requires, shall have the meaning it has under the law of that State Party with respect to taxes to which this Convention applies. Article 4 1. For the purposes of this Convention, “resident of a Contracting State” means any person taxable under the law of that State Party by virtue of his domicile, domicile, domicile, place of business or registered office or any other criterion of a similar nature. 2. Where a person resides in both States Parties pursuant to paragraph 1 of this Article, the competent authorities of the Contracting States shall designate by common accord the Contracting State in which that person is considered to be established for the purposes of this Convention. Article 5 1. For the purposes of this Convention, “permanent establishment” means a permanent establishment by which the business of an enterprise is carried on in whole or in part. (2) the term `permanent establishment` includes, in particular: (a) a place of administration; b. a branch; c.
an office; d. a factory; e. a workshop; f. a mine, oil or gas well, quarry or other natural resource extraction site; g. a warehouse in respect of a person who provides storage facilities for others; h. an agricultural operation, plantation or other place where agriculture, forestry, plantations or related activities are carried on; Me…